- 2 -
trade or business; respondent concedes Ps are entitled
to capital loss carryover deductions.
3. Held, further, Ps are liable for additions to
tax under sec. 6651(a), I.R.C. 1986, for 1987, and
under sec. 6653(a), I.R.C. 1986, for 1986, 1987, and
1988.
4. Held, further, Ps are not liable for additions
to tax under sec. 6661, I.R.C. 1986, for 1986, 1987,
and 1988.
Melvin J. Laney and Carolyn A. Laney, pro sese.
Diane D. Helfgott, Robert Dietz, and Kristine A. Roth, for
respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHABOT, Judge: Respondent determined deficiencies in
Federal individual income tax and additions to tax under sections
6651(a)1 (failure to timely file tax returns), 6653(a)(1)
(negligence, etc.), and 6661 (substantial understatement of
income tax liability) against petitioners as follows:
Additions to Tax
Sec. Sec. Sec. Sec. Sec.
Year Deficiency1 6651(a) 6653(a)(1)(A) 6653(a)(1)(B) 6653(a)(1) 6661
1986 $14,096 $331 $705 2 --- $3,524
1987 9,159 2,052 458 2 --- 2,290
1988 8,582 429 --- --- $429 2,146
1 Of these amounts, $3,070 for 1987 and $3,776 for 1988 are self-employment taxes
under ch. 2; the remainders are income taxes under ch. 1.
1 Unless indicated otherwise, all section and chapter
references are to sections and chapters of the Internal Revenue
Code of 1986 as in effect for the years in issue.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011